Final regulations published on May 28 provide that the requirement to report contributor names and addresses on Schedule B (“Schedule of Contributors”) of IRS Form 990, “Return of Organization Exempt From Income Tax,” or Form 990-EZ, ‘‘Short Form Return of Organization Exempt From Income Tax;’’ generally applies to returns filed by only Section 501(c)(3) organizations and Section 527 political organizations. Other tax-exempt organizations, such as Section 501(c)(4) and Section 501(c)(6) organizations, are relieved of reporting contributor names and addresses on the Schedule B, although they still must report the amount of each contribution on the form and maintain contributor names and addresses in their internal books and records. The final regulations adopt proposed regulations published in 2019.
The preamble to the final regulations explains that reporting contributor names and addresses poses a risk of inadvertently disclosing nonpublic information because information on Schedule B generally must be redacted. By not requiring that all tax-exempt organizations include contributor names on the Schedule B, the final regulations reduce the risk of inadvertent disclosure as well as the concern that supporters of certain causes or organizations might face reprisals (such as harassment) or other adverse consequences if their contributor status is made public.
